Do I need a CPSR for handmade soap?
Usually, yes. A bar sold to wash with is doing one of the things in the Art. 2(1)(a) definition of a cosmetic product, so it is normally treated as one, and a cosmetic placed on the EU market needs a safety report (Art. 10, Reg. (EC) 1223/2009). We could not find a small-batch or small-business exemption in the Regulation: the obligations attach to the product, not to the size of the business.
Is handmade soap a cosmetic?
The definition, in Art. 2(1)(a), Reg. (EC) 1223/2009:
'cosmetic product' means any substance or mixture intended to be placed in contact with the external parts of the human body (epidermis, hair system, nails, lips and external genital organs) or with the teeth and the mucous membranes of the oral cavity with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition or correcting body odours
Soap is usually a cosmetic. A bar you sell to wash with is doing the cleaning job in that definition.
Intended use decides it, not the recipe. The definition turns on a purpose that is exclusively or mainly one of those listed. A product presented as preventing or treating disease is presented for a different purpose, and the borderline with medicinal products is decided under Directive 2001/83/EC rather than under this Regulation.
A soap that never goes on the body is not a cosmetic. A soap sold for laundry or for cleaning surfaces is not intended to go on the body, so it is not a cosmetic — in the same way a candle is not.
Is there an exemption for small batches, hobby sellers or craft fairs?
We could not find one in Regulation (EC) 1223/2009. The obligations attach to the product being placed on the market, not to the size of the business placing it.
A craft fair is not outside the Regulation either. "Making available on the market" is any supply of a cosmetic product for distribution, consumption or use on the market "in the course of a commercial activity, whether in return for payment or free of charge" (Art. 2(1)(g)); placing on the market is a product's first making available on the market (Art. 2(1)(h)). A stall is a commercial activity.
Soap you give to friends and family outside any commercial activity is a different question from soap you sell. Bring us the actual arrangement rather than assuming either way.
The minimum before your first EU sale
Five things, the same for a bar of soap as for a serum. Each is explained in what EU cosmetics law actually says:
- A responsible person established in the Union (Art. 4) — the role.
- A safety assessment and safety report (Art. 10, Annex I) — what a CPSR is.
- A product information file (Art. 11) — the PIF checklist.
- A CPNP notification (Art. 13) — how CPNP works.
- A compliant label (Art. 19) — whose address goes on it.
What it costs for a soap
Our Simple band covers products that wash off or contain no water at all — a soap, a shampoo, a body wash, a balm, an oil — at €345, founding price. What the band covers, and the other lines →
Questions people ask
Is handmade soap a cosmetic under EU law?
A bar sold to wash with is doing one of the things in the Art. 2(1)(a) definition, so it is normally treated as a cosmetic. Presentation and intended use decide it.
Do I need a CPSR for a free sample?
The definition of making available on the market covers supply "whether in return for payment or free of charge" (Art. 2(1)(g), Reg. (EC) 1223/2009), so free does not by itself put a sample outside the Regulation. Bring us the actual arrangement — who gets it, on what terms — rather than assuming it does.
Does each scent need its own report?
A fragrance change usually is not inside the same assessment, because a different fragrance is a different set of substances at different levels. We tell you which of your variants sit inside one assessment and which need their own before you commit.
Start with the free check — see what your listing is missing, while you wait.